-21-
and (9) whether elements of personal pleasure or recreation are
involved. Id.
No factor or set of factors is controlling, nor is the
existence of a majority of factors favoring or disfavoring a
profit objective necessarily controlling. Hendricks v.
Commissioner, 32 F.3d 94, 98 (4th Cir. 1994), affg. T.C. Memo.
1993-396; Brannen v. Commissioner, 722 F.2d 695, 704 (11th Cir.
1984), affg. 78 T.C. 471 (1982); sec. 1.183-2(b), Income Tax
Regs. The individual facts and circumstances of each case are
the primary test. Keanini v. Commissioner, supra; Allen v.
Commissioner, supra at 34; sec. 1.183-2(b), Income Tax Regs.
Petitioners argue that, in determining whether they had a
primary, predominant or principal purpose and intent of realizing
an economic profit from the jet charter activity independent of
tax savings, we should take into account the increased
profitability of CFI due to using petitioners’ jet charter
service. Petitioners have proved, however, that they operated
the jet charter activity for profit independent of its effect on
the profitability of CFI. Therefore, we do not address this
issue.
D. Application of the Factors
1. The Manner in Which the Taxpayer Carried On the
Activity
We begin by examining the manner in which petitioners
carried on the jet charter activity. The fact that a taxpayer
carries on an activity in a businesslike manner may indicate a
profit objective. Sec. 1.183-2(b)(1), Income Tax Regs. In
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